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Sentencing Guidelines – Enhancement

7th Circuit Court of Appeals

Case Name: United States of America v. Elston Stevenson

Case No.: 20-2261

Officials: KANNE, BRENNAN, and SCUDDER, Circuit Judges.

Focus: Sentencing Guidelines – Enhancement

Elston Stevenson possessed a firearm as a felon, and as an armed career criminal he received an enhanced sentence. In the district court and on appeal, he challenges whether, given that state officials sent him a restoration of rights letter, two of his prior Illinois state convictions could support that enhancement. The district court concluded that Stevenson did not establish by a preponderance of the evidence that the letter in question pertained to those predicate convictions. That court did not clearly err, so we affirm.


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Derek A Hawkins is Corporate Counsel, at Salesforce.

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